Assess whether a special-purpose program is well designed or a pretext

SITUATION The working file is mortgage pricing residual by prohibited-basis group after a DOJ or CFPB monitor request for pricing files. CRA strategist in a manufactured-housing lender with dealer-originated files has to name A special-purpose program is well designed or A pretext for this Fair Lending Pricing and Credit Limits file.

DECISION CRA strategist in a manufactured-housing lender with dealer-originated files must choose A special-purpose program is well designed / A pretext using mortgage pricing residual by prohibited-basis group after a DOJ or CFPB monitor request for pricing files.

HYPOTHESES TO TEST 1. Mortgage pricing residual by prohibited-basis group reads as A special-purpose program is well designed once a DOJ or CFPB monitor request for pricing files is lined up to the same Fair Lending population. 2. Mortgage pricing residual by prohibited-basis group is closer to A pretext after a DOJ or CFPB monitor request for pricing files; A special-purpose program is well designed would over-claim this Pricing and Credit Limits extract. 3. A dual reading is still live in mortgage pricing residual by prohibited-basis group for CRA strategist in a manufactured-housing lender with dealer-originated files. 4. Mortgage pricing residual by prohibited-basis group is missing the fact CRA strategist needs after a DOJ or CFPB monitor request for pricing files; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Flag any disparate-impact table CRA strategist cannot explain from mortgage pricing residual by prohibited-basis group. 2. Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend. 3. Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group. 4. For this Fair Lending Pricing and Credit Limits file, read mortgage pricing residual by prohibited-basis group against a DOJ or CFPB monitor request for pricing files and write the one fact that would move a special-purpose program is for CRA strategist.

RECOMMENDATION Choose A special-purpose program is well designed / A pretext on this Fair Lending / Pricing and Credit Limits packet (mortgage pricing residual by prohibited-basis group after a DOJ or CFPB monitor request for pricing files). The follow-on Pricing and Credit Limits action is what CRA strategist does next: implement the option, assign an owner, and log the missing fact.

COMMAND RETURNS - Bottom-line Fair Lending option on a special-purpose program is, then the evidence in mortgage pricing residual by prohibited-basis group, then the action for CRA strategist - Hypothesis scorecard against mortgage pricing residual by prohibited-basis group: supported / rejected / untestable - Regulatory or exam hook Pricing and Credit Limits would cite - Pricing and Credit Limits finding in mortgage pricing residual by prohibited-basis group that a second reviewer can re-perform